## Facts

- Container Applications International, Inc. (CAI) leased cargo containers to Lykes Bros. Steamship Co., Inc. (Lykes) for use in Lykes’s shipping business.
- The parties’ lease contemplated fleet-wide use: CAI supplied containers in bulk, and Lykes could place containers on any of its vessels as business needs required.
- The lease limited use to vessels owned and/or operated by Lykes and to land transport connected with ocean carriage.
- CAI made containers available for pickup at multiple locations worldwide, and Lykes obtained them as needed.
- No container was delivered directly to any particular Lykes vessel, and the lease paperwork did not identify any vessel, allocate containers to a named vessel, or otherwise designate containers for specific ships.
- At the time the containers were furnished, neither CAI nor Lykes knew which vessels would ultimately use any particular container; Lykes later decided, in its own discretion, how to allocate containers across vessels (and related transport).
- The lease required Lykes to keep tracking information showing which containers were used on which vessels and for what periods.
- Lykes later filed for bankruptcy owing CAI unpaid container lease charges.
- In the bankruptcy proceeding, CAI sought to enforce maritime liens against various Lykes vessels under the Federal Maritime Lien Act (FMLA), asserting that each vessel’s use of CAI containers supported an in rem lien.

## Issues

1. Whether a supplier “provid[es] necessaries to a vessel” under the FMLA when it leases containers in bulk to a fleet owner, without delivering to or designating the containers for any specific vessel at the time of furnishing.
2. Whether later tracking records tying particular containers to particular vessels can supply the vessel-specific connection required for a maritime lien.

## Decision

- The Eleventh Circuit affirmed summary judgment for Lykes, which disallowed CAI’s asserted maritime liens.
- The court held that furnishing containers in bulk to a fleet owner—where the owner later chooses which vessels will use them and the containers are not delivered to or designated for identified vessels when supplied—does not satisfy the FMLA requirement that necessaries be provided “to a vessel.”
- The court rejected CAI’s reliance on after-the-fact tracking data, concluding that retroactive tracing of use did not convert a fleet-wide supply arrangement into vessel-specific furnishing at the time the containers were provided.

## Legal Principles

- The FMLA grants a maritime lien only to a person providing “necessaries to a vessel” on the order of the owner or an authorized person; the statutory focus is a vessel-specific supply of necessaries, not a supply to the owner’s general operations. (46 U.S.C. §§ 31341–31343)
- Maritime liens are strictly construed; courts do not extend them beyond what the statute and established lien doctrine allow.
- When goods or equipment are supplied on a fleet-wide basis, a lien generally requires a vessel-specific connection at the time of furnishing (such as delivery to a named vessel or documentation designating the goods for that vessel).
- Later records showing which vessel used an item, standing alone, do not create the required vessel-specific provision if the supplier initially furnished the items to the owner without any vessel designation.

## Conclusion

In re Container Applications International, Inc. holds that a container lessor does not obtain maritime liens under the FMLA when it supplies containers in bulk to a shipowner’s fleet without delivering to, or designating for, particular vessels at the time of supply; later tracking that shows which vessels used the containers cannot supply the missing vessel-specific link, so the supplier’s claim remains a non-lien claim in the bankruptcy case.


In re Container Applications International, Inc., 233 F.3d 1361 (2000)